(Court opinion corrected 5/13/20.) Court held fitness hearing and found that Respondent parents were unfit to parent their minor daughter, by reason of their failure to complete the services required by the service plans. After a best interest hearing, court found that it was in the best interests of the minor that Respondents' parental rights be terminated. Court failed to satisfy requirements of section 2-18(4)(a) because it failed to elicit any testimony as to the production of the service plans. State failed to provide any testimony, other than that of one caseworker, or evidence to satisfy the 3-prong foundational requirements for business records exception.Court erred by allowing caseworker to testify as to information she gleaned from reading the case file. She became a caseworker on this case 2 months after the close of the relevant 9-month time period measuring unfitness. (LYTTON and WRIGHT, concurring.)
Illinois Appellate Court
Civil Court
Termination of Parental Rights